Why are HCSA licensees allowed to claim that they can treat conditions of the human body in advertisement, while non-HCSA licensees (e.g., private psychological service providers/ clinics) are not allowed to do so? For example, IMH and SGH (HCSA-licensees) can state that their psychological services can treat mental conditions, while psychological service providers/ clinics (non-HCSA licensees) are not allowed to.
In the example provided, the Psychiatry Outpatient Clinics at IMH and SGH are run by a multi-disciplinary team of psychiatrists (registered medical practitioners), nurses and clinical psychologists that are employed or engaged by the hospital licensee to run a licensed outpatient medical service. The allied health services provided within this team are considered incidental to the overall doctor-led licensed Outpatient Medical Service (OMS) offered at these hospitals.
HCSA licensees are subject to the requirements under the HCSA and its regulations. Their advertisements are also regulated under the HCS(Advertisement) Regulations
On the other hand, standalone private psychology service providers which are non-HCSA licensees, operate independently without overall governance by a doctor-led licensed OMS. Hence, they are not subject to the requirements under the HCSA and its regulations.
Related questions
Do the requirements under Section 31B of the HCSA apply to all clinical psychologists who wish to use the protected title, “Dr” in advertisements regardless of whether they practise at licensed (e.g., IMH and SGH) or non-licensed healthcare service providers (e.g. private psychological service providers/ clinics)?
Who does the prohibition under Section 31A of the HCSA apply to?
Is advertising of educational talks/ workshops/ lectures on psychological interventions for mental conditions to members of the public considered as a healthcare advertisement? If yes, are these advertisements subject to the requirements under Section 31A and B of the HCSA?
Should clinical psychologists become registered healthcare professionals in future (i.e., they are included under Second Schedule of the AHPA), would they still need to comply with Section 31A and B of the HCSA?
